Traduction de «controlled foreign company » (Anglais → Français) :

119. Calls on the Commission to issue clear legislation on the definition of economic substance, value creation and permanent establishment, with a view to tackling, in particular, the issue of letterbox companies, and to develop EU criteria and legislation for the treatment of RD, compatible with, but not limited to, the work of the OECD on the matter, since Member States are currently reforming their strategy in that regard, often cumulatively with subsidies; stresses that such legislation should clearly indicate that there must be a direct link between the preferential regimes granted by the tax administration and the underlying RD a ...[+++]ctivities; calls on the Commission to revise EU legislation on controlled foreign companies and its application in accordance with the Cadbury Schweppes judgment of the European Court of Justice (C-196/04) in order to ensure full use of controlled foreign companies beyond situations of wholly artificial arrangements to avoid cases of double non-taxation; calls on the Commission to make proposals for harmonising rules on controlled foreign companies in the EU;

154. Calls on the Commission to use all the tools at its disposal to foster a more coordinated approach vis-à-vis developed countries in order to promote greater reciprocity in tax matters, in particular with regard to the exchange of information with the United States of America following the entry into force of the Foreign Account Tax Compliance Act; calls also on the Commission, against the background of the agreement of 27 May 2015 between the EU and Switzerland on the automatic exchange of financial account information, to monitor carefully, with a view to preserving the single market, the agreed phasing out of some harmful tax pra ...[+++]ctices in Switzerland, in line with BEPS guidelines, and that no new harmful tax measures are introduced in the future; calls on the Commission in its ongoing negotiations with Switzerland to suggest the introduction of controlled foreign companies rules in Swiss law; insists that the Commission must ensure that Switzerland follows the EU approach on taxation and report to Parliament;

152. Calls on the Commission to use all the tools at its disposal to foster a more coordinated approach vis-à-vis developed countries in order to promote greater reciprocity in tax matters, in particular with regard to the exchange of information with the United States of America following the entry into force of the Foreign Account Tax Compliance Act; calls also on the Commission, against the background of the agreement of 27 May 2015 between the EU and Switzerland on the automatic exchange of financial account information, to monitor carefully, with a view to preserving the single market, the agreed phasing out of some harmful tax pra ...[+++]ctices in Switzerland, in line with BEPS guidelines, and that no new harmful tax measures are introduced in the future; calls on the Commission in its ongoing negotiations with Switzerland to suggest the introduction of controlled foreign companies rules in Swiss law; insists that the Commission must ensure that Switzerland follows the EU approach on taxation and report to Parliament;

These measures should include limitations on the deductibility of interest paid to associated enterprises resident for tax purposes in a low-tax country outside the Union which does not exchange information with the Member State of the payer based on an agreement comparable to Council Directive 2011/16/EU concerning mutual assistance by the competent authorities of the Member States in the field of direct taxation and taxation of insurance premiums and rules on controlled foreign companies.

Acquisitions by foreign state-owned or controlled companies in these strategic areas may allow third countries to use these assets not only to the detriment of the EU's technological edge, but also to put our security or public order at risk.

Korea National Insurance Corporation (KNIC), a State-owned and controlled company, is generating substantial foreign exchange revenue which could contribute to the DPRK's nuclear-related, ballistic missile-related or other weapons of mass destruction-related programmes.